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When an employee of the YMCA was accused of improper touching of minors, the Y's general counsel recommended that its Board hire an outside entity to make proposals regarding policies and procedures in light of the allegations. The board followed counsel's advice and the report was prepard in anticipation of litigation.

After suit was filed, the plaintiffs sought access to the report. In a decision reversing the lower court's order to disclose the report, the Rhode Island Supreme Court held that the work product doctrine shielded the report from diusclosure. (Mike Frisch)